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Introduction

The Department of Health, as part of Special Action Group on Obesity commissioned by the Minister for Health, Leo Varadkar, has invited the Restaurants Association of Ireland (RAI) to make a submission regarding the displaying of Calories on Menus.

The RAI would like to thank the Department of Health for the invitation to make this submission.

The RAI fully appreciates the importance of the work being undertaken by the Department of Health and the Special Action Group on Obesity. The RAI recognises the current need to address the area of obesity in Ireland. Recent Budget submissions by the RAI (2012, 2013, 2014, 2015, 2016) have repeatedly called for the Establishment of a Nutrition and Healthy Eating in the Primary and Secondary School Syllabi. The Association is firmly of the belief that education on calories and nutrition would be the best policy direction rather than legislation on calories.

The Irish Restaurant Industry – An Overview

With over 3,000 restaurants in Ireland, the Restaurant sector employs 72,000 people and contributes €2 billion to the Irish economy each year. The RAI now represents in excess of 1,500 members with establishments representing fine dining, casual dining, ethnic, family, gastro pubs, hotel restaurants, cafes and some fast food operations.

The Restaurant sector encompasses a large number of owner operated SMEs, but is also a crucial supporter of small businesses, local agriculture and food producers throughout the country. In what has been a very difficult and challenging economic environment, the restaurant and tourism sector has stood out like a beacon of light over the past couple of years with an increase of over 30,000 jobs in the Foodservice & Accommodation sector.[1] The ability to increase prices is still very limited and with many of the costs of doing business under pressure, the sector continues to be characterised by tight margins, challenging trading conditions and a severe Chef shortage. Restaurants deal with on average, twenty-five different agencies and authorities in the day to day running of their business. Now is not a time for imposing further red-tape on business.

Over the past number of years the Restaurants Association of Ireland has engaged in several educational pieces regarding healthy eating the promotion of fresh Irish produce.

Kids Size Me

Kids Size Me is a joint initiative from the Restaurants Association of Ireland and the Nutrition and Health Foundation[2] (NHF) on the provision of child size portions of adult meals in restaurants.

The initiative aims to ensure children have access to healthier food options when dining out by making child size portions of adult meals available as an alternative to ordering from the standard children’s menu.

Voluntary guidelines have been devised by Dr. Muireann Cullen, Dietician and Manager of the Nutrition and Health Foundation.

By making child size portions of adult meals available in addition to the standard kids menu, participating restaurants will be able to give more value to their customers as well as tackle Ireland’s growing childhood obesity problem. In 2013, the Nutrition and Health Foundation conducted a survey on this initiative and found that;

52% of parents surveyed brought children out to eat once a month and 18% brought them out every fortnight.

98% of parents want child size portions of adult meals to be available in restaurants

53% of children already eat from the adult menu, but this is shown to lead to overeating due to the large portions

The top choice for children’s menus was “child size potions of adult meals” (88%)

Value and portion size are intrinsically linked and this creates an opportunity to show parents the value available through children’s meals

Child size portions of adult meals appeals to parents who want to feed their children healthier options while eating out

Parents are more willing to eat out with children when restaurants offer them a good value

55% of parents spent €5-€50 on a child’s meal and 32% spent €7.51-€10, the majority believed this was worth the money

With 1 in 4 nine year olds overweight or obese in Ireland, it is important that parents are given greater, healthier choices when they eat out with their children.

RAI & St. Angela’s School of Home Economics Schools Cookery Competition

Educating the youth of Ireland on cookery as a career and not just a pastime has become an important focus of the Association.

In 2014 the Restaurants Association of Ireland and St. Angelas Home Economics School Sligo came together to run an all-island cookery competition that is open to all students in post-primary schools on the island of Ireland and Youthreach Centres in the Republic of Ireland. The theme for 2014 was Fine Dine at Mine, gave students an opportunity to create tasty, healthy and affordable restaurant meals at home and students were mentored by their local restaurants.

Happy Hearts Campaign

The Restaurants Association of Ireland supports the Irish Heart Foundation Happy Hearts Eat Out Campaign, a campaign which rose awareness of portion sizes when eating out, in addition to encouraging people to choose healthy options from menus.

Bord Bia Just Ask!

The Restaurants Association of Ireland has been a long time supporter and advocate of Bord Bia’s public awareness campaign that aims to encourages consumers when eating out to look for information on where their food is sourced (particularly fresh meat, fish, fruit and vegetables) and to encourage Chefs to provide this information on their menus.

Bord Bia conducted a survey[3] in July 2015 amongst previous recipients of the Bord Bia Just Ask! Monthly Award, a campaign that aims to encourage diners to look for information on where the food on their plate comes from when eating out and inspire chefs to provide such information on their menus. Over 95% of respondents confirmed that they have increased the amount of local suppliers that they are working with within the past 12 months, with 85% of respondents spending in excess of 40% of their monthly budget on local food and drink.

Foodie Towns

The Restaurants Association of Ireland created the first ever ‘Foodie Town’s competition in 2014 and the 2015 competition is currently underway.

The ‘Foodie Town of Ireland’ award recognises a town/destination that actively promotes itself through joint promotional activities such as food festivals, gourmet trails or farmers’ markets as well as great dining experiences for locals and visitors alike. The winning Irish town/destination will have established a local producer/supplier network which is utilised and promoted by local businesses. Plans for future growth and investment into the food and hospitality industry at a local level will also be taken into consideration by judges. Education, training, development and employment will be key components of the ultimate foodie destination.

Obesity Policy and Action Plan for Ireland

The Restaurants Association was happy to par-take in the Consultation day on the Department of Health’s Obesity Policy and Action Plan for Ireland 2015-2025 in April 2015.

Mandatory Posting of Calories on Menus

The RAI would like to say that at the out-set it is opposed to the mandatory posting of calories on menus in all food-service establishments for the following reasons;

Cost of implementation is estimated between €5,000 to €10,000 depending on the size of the establishment. A high end hotel could be looking at anywhere from €35,000 upwards. Costs come down to staff training, labour costs, hiring of nutritionist, menu changes/printing, website development changes. Some establishments change their menu frequently adding to higher costs.

Consumers do not dine out in restaurants 7 days a week. People decide to dine out at food service outlets for pleasure, as a treat for themselves. If calories on menus were to be implemented, you’ll have a social stigma attached. Will diners frown at each others choices of one picks a high calorific meal?

Nutritional labelling has been in affect for many years in Ireland and still the country’s collective weight is increasing.

The RAI is a firm believer in education not legislation where calories are concerned. There should be more focus on educating children and adults on nutrition rather than calorie counts. Calories on their own are not a good measure of healthy menus. Calories are one part of calculating a healthy diet. As reported by Joe Weisenthal[4] in Business Insider: “Calorie counts create the illusion of some unified measure of healthiness, as if low calories always equaled good and high calories always equal bad.”

Enforcing calorie count menus by law will cost the state ten of millions of euros to implement. The state will have to test and re-test food used by food service outlets to make sure it is living up to the calories it has posted on its menus. There could also be a trend of food service outlets under-recording the calories on their menus, which will need enforcement from the government. This means more money will be needed on staff and funding by the government.

Stifling Chef creativity. Chefs are spending more and more time doing paperwork than in the kitchen. The recent introduction of allergen legislation has even further eroded their time cooking.

Ireland already has a high tax regime on certain foods including beverages and confectionaries, and we fear that people would travel over the border to purchase these items if higher taxes were imposed.

The report of the consultation on page 22 states that ‘Calorie posting alone, though welcomed, was not thought to be a high priority, given current evident. Other respondents felt there was an over emphasis on calorie posting while the emphasis should be on nutrition not calories’.

We must also take in to account the other views of those who attended the consultation day. Calorie posting on menus needs to be broader and reflect overall nutrition, for example adopting a traffic light system…..It was proposed that there should be broader reference to legislation for example on adverting foods high in fat, salt and sugar….’

Page 27 of the report goes on to state that one of the priorities for the Department of Health is to ‘Strengthen implementation of legislation to support calories on menus’

The RAI does not agree with this being a priority for the Department given the comments made during the consultation (page 22 and as written above) in answering the question at the consultation ‘Which three of the above seem to you to be the most important?’

The RAI echoes the comments on page 35 of the report on the issue of posting calories on menus that ‘this needs to be refined to take in to account different types of food outlets. The cost especially to small food businesses should be recognised and accuracy of data was of concern. There needs to be further clarification on implementation and compliance to avoid this becoming a ‘tick box’ exercise’.

Evidence from the United States[5] now suggests that the best practice is to have mandatory posting of calories on menus for establishments that have 20 units or more.

Education

As stated earlier in this submission, the RAI supports elements of the report on education, particularly the outcome that a longer term strategic policy-led ‘whole school approach’ should be taken with a particular focus on disadvantaged education settings.

The RAI is happy to play an active role in continuing to promote initiative’s as outlined in pages 4 and 5 of this document as well as actively working the Departments of Health, Education and Tourism & Sports.

The RAI would like to see specific subjects introduced at primary and second level focusing on food, healthy eating and cooking. Home Economics (Scientific & Social) in its current guise at second level is not compulsory and is quite a complex subject covering Food Studies, Social Studies, Family Resource Management, Consumer Studies, and Home Design.

Education on food should be thought from an early age in Montessori to primary to secondary level and across our youthreach centres.

The RAI believe that it should be mandatory for all new school builds to have canteen facilities and built kitchens thus providing students with easily accessible and affordable dining options rather than children leaving school grounds to go to shopping centres or fast food outlets at lunchtime. (Healthy Ireland survey found that 75% of 15-24 year olds snack twice a day) Vending machines are another element of school life that the RAI feel should be banned. It is ludicrous to ask casual to high-end restaurants to put calories on their menus and not ban vending machines from schools.

Special Advisory Group on Obesity (SAGO)

The RAI agrees with the comments made in the report that ‘greater clarity’ (page 51 and 53) should be made on the membership of SAGO, the selection process and the terms of reference. The RAI would have reservations over the make up of this group as it consists mainly of those who are currently employed by the Department of Health and who report to the Minister for Health. The RAI would like to re-iterate the comments in the report that SAGO should be ‘cross-sectoral’

Healthy Ireland Survey

Going forward the RAI would like to see the section on Diet & Nutrition to look at eating out habits. This would then tie in to the core principle of the Obesity Policy and Action Plan core principle that the plan should be ‘Evidence informed’ particularly when looking at calories on menus.

Conclusion

Will it work?

In a study by J. Swartz et al (2011 – International Journal of Behavourious Nutrition and Physical Activity) it found that ‘calorie menu labelling has no effect or only a small effect on the number of calories that people order and consumer’

Eat Well Global ‘A Global perspective on Menu Labelling’[6] found in their review of 31 studies found that “providing information at the point of purchase is not enough to influence purchasing behaviours of most fast food restaurant consumers. However certain groups of consumers are more likely to use calories information when selecting meals. This includes women, wealthier classes….government and industry should consider how labelling may affect different subsets of the population’.

The RAI would once again like to thank the Department of Health for their time in reading this submission. Should you wish further clarification on any points mentioned herein, we would be happy to assist.